Finding 1165395 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2025-12-18
Audit: 376003
Organization: Union College (KY)
Auditor: SIKICH CPA LLC

AI Summary

  • Core Issue: Timely payment of credit balances was not met for 20% of sampled students, indicating a material weakness in compliance.
  • Impacted Requirements: Violations of 34 CFR 668.162 (d) regarding the handling of Title IV funds under heightened cash monitoring.
  • Recommended Follow-Up: Enhance controls to ensure credit balances are refunded before requesting funds to prevent future violations.

Finding Text

2025-001 - Student Financial Assistance Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work-Study Program (c) Federal Perkins Loan (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education Grants (TEACH Grants) (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Criteria: 34 CFR 668.162 (d) states: Under the heightened cash monitoring payment method, an institution must credit a student’s ledger account for the amount of Title IV, HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due before the institution submits a request for funds. Condition: We tested 40 students and credit balances were not paid in a timely manner for 8 students (20%). We consider this condition to be a material weakness for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical Sampling was not used in making sample selections. Questioned Costs: $62,882. Cause and Effect: The condition was caused by not paying credit balances prior to requesting funds. As a result, the Institution was holding funds that needed to be returned to the students and violated the special conditions of provisional certification of its Program Participation Agreement (PPA). Recommendation: As the University did refund the credit balances to students within 14 days of receipt of drawdown, we recommend the University increase controls over Heightened Cash Monitoring procedures and refunding credit balances prior to drawdown of funds. Views of Responsible Officials: Management agrees with this Single Audit Finding and response is included in the Corrective Action Plan.

Corrective Action Plan

2025-001 - Student Financial Assistance Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work-Study Program (c) Federal Perkins Loan (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education Grants (TEACH Grants) (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 - Year Ended June 30, 2025 Criteria: 34 CFR 668.162 (d) states: Under the heightened cash monitoring payment method, an institution must credit a student’s ledger account for the amount of Title IV, HEA program funds that the student or parent is eligible to receive, and pay the amount of any credit balance due before the institution submits a request for funds. Condition: We tested 40 students and credit balances were not paid in a timely manner for 8 students (20%). We consider this condition to be a material weakness for the Special Tests and Provisions compliance requirement and is not a repeated finding. Statistical Sampling was not used in making sample selections. Responsible Persons: Andra Butler and Jessica Justice Corrective Action Plan: Management agrees with the finding. Management has already implemented corrective actions to ensure that credit balances caused by federal funds are refunded prior to those federal funds being requested by the University. Financial Aid notifies the Business Office when all postings are complete. The Business Office then runs a disbursement roster and refunds those students with credit balances. Once the refunds have been delivered to the students, the Business Office draws in the funds per the disbursement roster totals. The disbursement roster is retained as support for the drawdown amount Implementation Date: Fall 2025

Categories

Student Financial Aid Special Tests & Provisions

Other Findings in this Audit

  • 1165390 2025-001
    Material Weakness Repeat
  • 1165391 2025-001
    Material Weakness Repeat
  • 1165392 2025-001
    Material Weakness Repeat
  • 1165393 2025-001
    Material Weakness Repeat
  • 1165394 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $4.69M
84.063 FEDERAL PELL GRANT PROGRAM $2.86M
84.042 TRIO STUDENT SUPPORT SERVICES $322,421
84.031 HIGHER EDUCATION INSTITUTIONAL AID $213,693
84.038 FEDERAL PERKINS LOAN PROGRAM $195,979
84.033 FEDERAL WORK-STUDY PROGRAM $172,123
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $62,343
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $26,877